principal owner(s).
Our firm is an SEC registered investment advisory firm providing investment management, portfolio management
and wealth management services to individual investors and small to medium sized institutional investors in the
United States. We (or our predecessors) have been in business since 1988. We provide separate account portfolio
management, including supervisory services and wealth management services on a fee-only basis to our clients. We
are compensated on the basis of fees, or a percentage of assets under our management.
On a small minority of our accounts, we do not provide portfolio management on a discretionary basis, but instead
receive direction from our clients on how they would like their portfolios structured. We do this on a non-fee basis
as a courtesy, accommodation, and convenience to certain clients. Our office is located in Fayetteville, AR.
Principal Owners
The three principals of our firm, Kerry W. Bradley, CFA, MBA, Glenn E Atkins and Carla Muruaga-Atkins Trust,
and James B. Bell, CFA, collectively own a significant majority of our business. Kerry W. Bradley, CFA, MBA,
owns the majority of our firm and no other person or entity other than the three principals, owns more than 5% of
the firm.
particular type of advisory service, such as financial planning, quantitative analysis, or market timing,
explain the nature of that service in greater detail. If you provide investment advice only with respect to
limited types of investments, explain the type of investment advice you offer, and disclose that your advice is
limited to those types of investments.
Our business is fee only, separate account discretionary investment management, portfolio management and wealth
management services. Before engaging us, clients are generally required to enter into an Investment Advisory
Agreement with us, setting forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory
process, we will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with
the client’s designated investment objective(s). Once allocated, we provide ongoing supervision of the account(s).
“Fee only” investment management means that we charge a fee for managing your investment portfolio (see Fees &
Compensation later in this brochure), and do not earn a commission on securities bought and sold within your
account. We believe this more closely aligns our interests with yours. For instance, when we buy or sell a security
for your account we do so because we believe it is in your best interest to do so, not because we will earn a
commission on the transaction.
“Separate account” investment management means that your account is held in your name, under your tax
identification number and that your account is not commingled with the accounts of our other clients.
“Discretionary” means that you have authorized us to buy and sell securities for your account that we believe meet
the requirements of your Investment Policy Statement (see below) without notifying you in advance of our
transactions. Within a few days after we place buy or sell orders in your account you will receive a written or
electronic “trade confirmation” from your custodian that will provide you the details of the transaction we placed on
your behalf. You will also receive from us a quarterly statement which will provide you with a list of the securities
we have bought and sold in your account during the period.
We will primarily use the following types of securities in client accounts we manage:
1. Equities, or common stocks
2. Preferred stocks
3. Warrants
4. Corporate debt
5. Commercial paper
6. Certificates of deposit
7. Municipal securities
8. Mutual funds
a. open end
b. closed end
9. Exchange traded funds
10. American Depository Receipts (ADR’s)
11. United States government securities including agency securities
12. Option contracts
Your account may not contain each of the security types mentioned above.
We also manage assets on a discretionary basis in a sub-advisory capacity for other registered investment advisors.
We assist with the management of all or a portion of the client’s assets per the terms and conditions of the other
advisor’s Investment Advisory Agreement and Sub-Advisory Addendum, or per the terms of a Tri-Party agreement
between us, the other advisor, and their client.
In this arrangement we are considered the Manager and the other registered investment advisor is considered the
Adviser or Advisor. When acting in this capacity, we (the Manager) maintain day-to-day discretionary management
authority for the assets allocated to us by the Adviser. At all times, the Adviser maintains both the initial and
ongoing day-to-day relationship with the client, including initial and ongoing determination of client suitability for
the Manager’s investment strategies. Our obligation is limited to management of the allocated assets consistent with
the objective and/or strategy designated by the Adviser. We are not affiliated with these other Advisors.
We do not provide financial planning and related consulting services regarding non-investment related matters, such
as estate planning, tax planning, insurance, etc. Please Note: We do not serve as an attorney, accountant, or
insurance agency, and no portion of our services should be construed as providing these functions. Accordingly, we
do not prepare estate planning documents, tax returns or sell insurance products.
clients. Explain whether clients may impose restrictions on investing in certain securities or types of
securities.
All of the investment management services we provide to you are custom-tailored for your specific situation. We
take into account such considerations as your risk tolerance, your time horizon, your tax situation and your need or
desire for income or capital growth, among others. Although most of our clients choose not to do so, you have the
ability to request that we do or do not invest your portfolio in certain kinds of securities. Examples would include
tobacco companies, alcoholic beverage companies, and companies that supply military hardware, among others.
After we have discussed your risk tolerance, time horizon, and other items that are important for us to understand
your investment needs, we may draft a written Investment Policy Statement on your behalf that we will use as our
road map in how we manage and structure your investment portfolio. You should review this Investment Policy
Statement at least annually or more frequently if your personal situation changes and let us know if we should be
managing your investment portfolio differently.
In performing our services, we do not verify information received from you or from your other professionals and we
are thus authorized by you to rely on the information you provide to us in this regard. You should promptly notify us
if there is any change in your financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services to you.
For sub-advised accounts, we rely solely on information and instructions provided to us by your other Adviser.
the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and
(2) explain that you receive a portion of the wrap fee for your services.
Wrap fee programs are programs that “wrap” investment management and trading fees into one combined fee
structure. We do not participate in wrap fee programs.
basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which
you calculated the amounts.
As of December 31, 2023 we manage approximately $300,970,105 in discretionary assets and $13,273,901 in non-
discretionary assets. Thus, total assets under management are approximately $314,244,006.
MISCELLANEOUS PROVISIONS
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new
deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the
sweep account will generally be lower than those available for other money market accounts. When this occurs, to
help mitigate the corresponding yield dispersion, we shall (usually within 30 days thereafter) generally (with
exceptions) purchase a higher yielding money market fund (or other type security) available on the
custodian’s platform, unless we reasonably anticipate that we will utilize the cash proceeds during the subsequent 30-
day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will
occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount
of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from
the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the
account. Please Note: The above does not apply to the cash component maintained within an actively managed
investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep
account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment
manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain
exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances
maintained in any unmanaged accounts.
Portfolio Activity. We have a fiduciary duty to provide services consistent with the client’s best interest. We will
review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors,
including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account
additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be
extended periods of time when Registrant determines that changes to a client’s portfolio are unnecessary. Clients
remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated
below, there can be no assurance that investment decisions made by us will be profitable or equal any specific
performance level(s).
Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s
engagement of us. Generally, with potential exceptions, we do not/would not recommend nor
follow such securities, and absent mitigating tax consequences or client direction to the contrary,
would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed
that the replacement securities purchased by us will outperform the liquidated positions. To the
contrary, different types of investments involve varying degrees of risk, and there can be no
assurance that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by us) will be profitable or
equal any specific performance level(s)In addition, there may be other securities and/or accounts
owned by the client for which we do not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which we do not maintain custodian access and/or
trading authority.
Corresponding Services/Fees: When agreed to by us, we shall: (1) remain available to discuss these
securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular
basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part
of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be
provided by us; and, (5) include the market value of all such securities for purposes of calculating advisory fee.
Cybersecurity Risk. The information technology systems and networks that we and our third-party service providers
use to provide services to our clients employ various controls that are designed to prevent cybersecurity incidents
stemming from intentional or unintentional actions that could cause significant interruptions in our operations and/or
result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and
our firm are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur
financial losses and/or other adverse consequences. Although we have established processes to reduce the risk of
cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that
we do not control the cybersecurity measures and policies employed by third-party service providers, issuers of
securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges and other
financial market operators and providers.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of
Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG
investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers
how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with
its employees, customers, and the communities in which it operates); and Governance (i.e., company management
considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to
those that do not, and could underperform broad market indices. Investors must accept these limitations, including
potential for underperformance. As with any type of investment (including any investment and/or investment
strategies recommended and/or undertaken by us), there can be no assurance that investment in ESG securities or
funds will be profitable, or prove successful. We do not maintain or advocate an ESG investment strategy, but will
seek to employ ESG if directed by a client to do so. If implemented, we shall rely upon the assessments undertaken by
the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or
portfolio’s underlying company securities meet a socially responsible mandate.
WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including
Bitcoin, we will advise the client to consider a potential investment in corresponding exchange traded securities, or an
allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a
digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a
method of protecting information and communications through the use of codes) to secure online transactions. Unlike
conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and
their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered
to be a speculative investment, we will not exercise discretionary authority to purchase a cryptocurrency investment
for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please
Note: We do not recommend or advocate the purchase of, or investment in, cryptocurrencies. We consider such an
investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment
must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal.